Outside Publication

On 26 October 2017, the Trump Administration sent the US Congress the initial list of entities within the Russian defence or intelligence sectors as required by Section 231(d) of the Countering America’s Adversaries Through Sanctions Act of 2017 (‘CAATSA’ or the ‘Act’) (Pub. L. 115-44). Under the Act, secondary sanctions must be imposed on any US or non-US person, wherever located, that the US President determines has engaged in a ‘significant transaction’ with any entity named on that list. The list appears on the US Department of State website at: www.state.govt/isn/caatsa/275116.htm.